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Home My WebLink About09-4810Our File No.: 212784 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 ' 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff NORTH STAR CAPITAL ACQUISITION LLC c/o Apothaker & Associates, P.C 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. ANDREA M HUGHEY 839 HUMMEL AVE LEMOYNE, PA 17043-1835 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 69 - 4810 NOTICE Civil tern, You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 r Our Filb No.: 212784 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 ' 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff NORTH STAR CAPITAL ACQUISITION ) LLC ) c/o Apothaker & Associates, P.C. ) 520 Fellowship Road C306 ) Mount Laurel, NJ 08054 ) Plaintiff, ) VS. ) ANDREA M HUGHEY ) 839 HUMMEL AVE ) LEMOYNE, PA 17043-1835 ) Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09- `/ F16 (2tZ;&I -c., CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is NORTH STAR CAPITAL ACQUISITION LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are ANDREA M HUGHEY, an adult individual residing at 839 HUMMEL AVE LEMOYNE, PA 17043-1835. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #4071100011148875; and said account was issued to Defendant(s) by WELLS FARGO FINANCIAL, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $4,882.50. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". above. Although demand has been made, Defendant(s) has failed to make payment of the amount due as WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $4,882.50 and requests this Court award costs to the extent pe tted by applicable law. APOTHAKER & A S IATES, P.C. Attorney f r P 'tiff A Law Firm Engag Debt C,ejilection BY: David J. Apothaker, Esquire Dated: 7/15/2009 Our File No.: 212784 VERIFICATION David J. Apothaker Esquire hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relatilf'91'4 unworn falsification to authorities. David J. ker, Esquire Plaintiff DATE: 7/15/2009 ANDREA M HUGHEY 839 HUMMEL AVE LEMOYNE, PA 17043-1835 NORTH STAR CAPITAL ACQUISITION LLC STATEMENT OF ACCOUNT Debtor's Name: Account Number: Original Creditor: Balance Due: Our File No.: 212784 ANDREA M HUGHEY 4071100011148875 WELLS FARGO FINANCIAL $4,882.50 EXHIBIT "A" ?J OR THE p QNSTARYt 2449 JUL 20 PM 12: 5 5 ?OUNITY P NNSYLVANA S. So Po A`I Y ?r'" aas ia9 Sheriff s Office of Cumberland County R Thomas Kline - , Sheri ~'~ `: ~.~ r ~ . ~~~~,~ Bt €~ttnbrrr~ Jr TN~ ~ ~' i;~,~'Y Ronny R Anderson !~ ~'~ Chief Deputy ~' '"~' , `~ ~° ~ ~ "' "' R f ~' ~" ~ .;~ " ( 0 Jody S Smith ~~~~` =. Civil Process Sergeant ~~ECE ~r ~wE ~r~~ai~~ ~La~~ ~ ~ ~' ~_ ~~ Edward L Schorpp Solicitor North Star Capital Acquisition LLC Case Number vs. Andrea M. Hughey 2009-4810 SHERIFF'S RETURN OF SERVICE 07/30/2009 07:13 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on July 30 2009 at 1913 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Andrea M. Hughey, by making known unto herself personally, defendant at 839 Hummel Avenue Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $42.40 July 31, 2009 SO ANSWERS, ~..I~ R THOMAS }~C~VE, SHERIFF ty -- ~ R ~~ Z Our file No.: 212784' APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorneys for Plaintiff Attorney ID# 5 5140 NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, vs. ANDREA M HUGHEY Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 09-4810 Civil Action L~ ~ D c ~ ao 0 N O O G~,1 STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on August 10, 2009, STIPULATED by and between Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, and Defendant, ANDREA M HUGHEY parties as follows: 1. Defendant agrees to pay the sum of $5,081.22, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $5,081.22 shall be paid by the by Defendant, ANDREA M HUGHEY, to the attorneys for Plaintiff in the following manner: a. $250.00 to be paid on or before August 28, 2009; b. $100.00 to be paid on or before the 20~' day of each month, beginning September 20, 2009 until paid in full. All checks are to made payable to NORTH STAR CAPITAL ACQUISITION LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 -_ • ., ' ~ _ Our file No.: 212784 3. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex pane, in the sum of $5,081.22, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, and default is not cured within ten (10) days, Plaintiff shall be entitled to obtain the entry of Judgment upon ex pane application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to ANDREA M HUGHEY by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm En~a~e~~-H'e6t Collection Y~ ly F. Scian, Esquire ANDRE Y 2~Q9 SEP -4 PM 3~ 0 i ~tvSYLVAi~A Our File No.: 212784 +' HE PR OTHON'i BAR APOTHAKER& ASSOCIATES, P.C. BY: David J. Apothaker, Esquire 2013 APR 18 P11 I. 43 Attorney I.D.# 38423 CUMBERLAND COUNTY 520 Fellowship Road C306 PENNSYLVANIA Mount Laurel,NJ 08054 (800) 672-0215 Attorney for Plaintiff NORTH STAR CAPITAL ) COURT OF COMMON PLEAS ACQUISITION LLC ) CUMBERLAND COUNTY ) Plaintiff, ) vs. ) ) NO. 09-4810 ANDREA M HUGHEY ) ) ) Defendant. ) PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER&AS •CIATES, P.C. Attorneys •r P,aintiff A Law Firm Engated i Debt Collection By: David J. Apot Mer, Esquire 11 111 11 11 1 111 l 11111111 1 11 1 11 11 * Q 2 1 2 7 8 4 D I S N 1 - *